APPENDIX 5: VISIT TO UNILEVER RESEARCH
AND DEVELOPMENT FACILITY AT COLWORTH, BEDFORDSHIRE |
19 May 2009
Member of the Sub-Committee taking part in the visit
were: Lord Haskel, Lord Krebs (Chairman), Lord Methuen, Lord Mitchell,
Baroness Neuberger, Baroness O'Neill of Bengarve, and the Earl
In attendance: Professor Stephen Holgate (Specialist
Adviser), Ms Rachel Newton (Policy Analyst) and Mr Antony
Meeting with Dr Jim Crilly (Executive Vice
President), Dr Julia Fentem (Head of Safety and Environmental
Assurance Centre), Dr Eddie Pelan (Platform Director, Unilever
Discover Organisation), Dr Mike Butler (Director, Materials
and Processing), Dr Bobbie Bradford (Product Toxicologist,
SEAC)), Dr Helen David (Lead Scientist, Environmental Protection,
SEAC) and Ms Helen Fenwick (Public Affairs Manager)
Presentation by Dr Jim Crilly
Dr Crilly welcomed the Committee to Unilever's
research and development (R&D) facility at Colworth, Bedfordshire.
Unilever was one of the world's largest food companies; it employed
around 170,000 employees and operated in around 100 countries
worldwide. The R&D facility at Colworth employed over 700
people, and contained Unilever's Safety and Environmental Assurance
Centre (SEAC) which assessed the safety of all Unilever products.
Presentation by Dr Eddie Pelan
Food already contained structures at the micro and
nanoscale. Margarine contained water droplets smaller than 10
microns across, with even smaller fat crystals interspersed between
them. Fruit juice contained plant material that was built from
nanoscale components, while Bailey's Irish Cream contained nano-emulsions
with an average droplet size of 190nm. Naturally occurring nanomaterials
found in food ranged in size from particles smaller than 100nm
found in drinks such as tea, beer and coffee, to protein structures
of around 300nm found in eggs or soy, to larger oil particles
of around 800nm found in substances such as milk. All food, including
processed food, was structured at the nanoscale, and consequently
the body had evolved to deal with nano-scaled materials over time.
Many of the major food companies were exploring the
nanoscale structuring of food. Between 2003 and 2006, around 40-70
patents were filed each year relating to food nanoscience. Unilever
was using nanoscience to gain a better understanding of the structure
of food in order to affect the functionality of food, such as
its composition, appearance, texture and taste, using a variety
of materials and assembly methods.
Nanomaterials were not simply substances smaller
than 100nm; the properties of many materials change over a range
of sizes. The important defining aspect was a change in
physical, chemical or biological properties compared to the bulk
material. Unilever was using food ingredients when exploring the
potential of nanotechnologies. There was a clear difference between
biodegradable nanotechnologies constructed from natural food grade
components, and all other forms of nanotechnologies. Nanotechnologies
had to be seen as a framework that enables the design of macroscopic
structures using nanoscale building blocks.
Tour of Measurement Science facility with Mike
The Committee were given a tour the Measurement Science
facility. Discussion focused on the following points:
- The need for expensive and complicated
equipment to detect and characterise nanomaterials in biological
- Even with appropriate equipment, observing nanomaterials
directly is a difficult and complicated process. Unilever was
constantly working on new methods of improving observation techniques.
Presentation by Dr Julia Fentem
Dr Fentem outlined the role that the Safety
and Environmental Assurance Centre (SEAC) plays within Unilever.
SEAC provided Unilever with independent scientific advice and
guidance to help identify and manage risks to consumers, workers
and the environment, and the environmental impact of Unilever
products. Responsibility for safety assessment was formally delegated
to SEAC by the Chief Executive, to ensure that product safety
approval was independent of categories, regions and functions.
SEAC was developing new risk and impact assessment
approaches to cope with new challenges and was building up its
in-house capability in hazard characterisation, exposure assessment
and risk and impact assessment. It fed into corporate policy on
all aspects of product safety, and considered the company's position
on wider ethical issues such as alternatives to animal testing
and the ethics of human research. It was also working with regulators
and policy-makers by sharing scientific evidence from its work,
as well as engaging with wider bodies such as industry partners,
trade associations and NGOs in developing and applying new safety
The process of incorporating new technologies into
food products can take years. Unilever identified ice structuring
protein (ISP) as a commercially viable ice-cream ingredient in
1994. SEAC finally gave ISP market approval in 2001after seven
years of safety and risk assessment alongside product development.
It was approved by the United States Food and Drug Administration
in 2003. Unilever submitted ISP for approval by the European Union
in 2006, and received novel foods approval in May 2009.
Discussion focused on the following points:
- Unilever was not very pro-active
at showing the public how it carries out its safety assessments.
While it could be argued that this might assure the public of
the safety of finished products, it was pointed out that consumers
need to feel that all food products on the market are safe; if
Unilever tried to use its comprehensive safety work as a marketing
tool for competitive advantage, it could have a serious impact
on consumer confidence in the entire food industry.
- SEAC discussions with regulators were typically
a constant, informal dialogue, rather than part of a more formal
Presentation by Dr Bobbie Bradford
Dr Bradford detailed the risk assessment process
followed by Unilever at SEAC, and in particular how it related
to the safety assessment of nanomaterials. Engineered nanomaterials
are substances that have been deliberately created, and are composed
of discrete functional and structural parts smaller than 100nm.
They had applications in a variety of industry sectors due to
their novel properties.
It was very difficult to quantify potential exposure
to nanomaterials. Research was underway into whether they can
move through natural biomembranes, such as from the lung to the
blood or from the blood to the brain. They may potentially accumulate
in the body, although it is not yet known in which organs this
might occur. Environmental exposure might occur through numerous
sources, ranging from the production process through to waste
disposal, and the behaviour of nanomaterials once they enter the
soil or water table is difficult to monitor or measure.
There were particular safety concerns over nanomaterials
that are bio-persistent. Compared to standard substances, nanomaterials
may have both an increased hazard, or an increased exposure, or
both. Both hazard and exposure must be known to quantify risk.
SEAC was working to assure the suitability of a risk
assessment framework for nanomaterials covering consumer, occupational
and environmental (COE) safety, tailored as required to meet the
specific concerns of nanomaterials. SEAC was informing the development
of this framework through participation in regulatory and industry-led
collaborations, which includes contributing to; the OECD working
party on nanomaterials; the DEFRA Nanoscience Initiative; the
International Life Sciences Institute's working party on Novel
Foods and Nanotechnology Task Force. It also supported both internal
and external research, including collaborations with academia,
and monitored the development of relevant regulatory legislation
and initiatives, including scientific opinions from relevant EU
and UK advisory committees.
Discussion focused on the following points:
- What types of nanomaterials posed
the highest risk. SEAC looked into whether normal food ingredients,
manufactured at the nanoscale, posed a higher risk. They concluded
that, since they would break down in the gut in the same way as
normal food, they were not a high risk safety concern. In contrast,
persistent nanomaterials or those presenting a brand new functionality
as a result of their small size were of more concern.
- Given the range and variety of nanomaterials,
it would be necessary to prioritise research to ensure that those
types of substances most likely to be used in food received early